PETITIONED PUBLIC HEALTH ASSESSMENT

KINGS CREEK
(a/k/a FORT BELKNAP INDIAN RESERVATION/ZORTMAN MINING INCORPORATED)
LODGEPOLE, BALINE COUNTY, MONTANA

APPENDIX A: ACRONYMS/SYMBOLS AND MAPS

MAPS

Figure 1. Fort Belknap Indian Reservation: Towns and Municipalities

Figure 2. Landusky and Zortman Mines Buffer Zones, Fort Belknap Indian Reservation

Figure 3. Surface Water Drainage, Fort Belknap Indian Reservation

Figure 4. Fort Belknap Indian Reservation: Zortman and Landusky Mines

APPENDIX B: PUBLIC HEALTH CONSULTATIONS

Appendix B was not available in electronic format for conversion to HTML at the time of preparation of this document. To obtain a hard copy of the document, please contact:

Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Attn: Chief, Program Evaluation, Records, and Information Services Branch E-56
1600 Clifton Road NE, Atlanta, Georgia 30333

APPENDIX C: DATA SETS

APPENDIX D: DIFFERENCES BETWEEN DATA SOURCES

Sampling Point Differences

Samples have not been collected in identical locations within each of the media (domestic drinkingwater, groundwater, and surface water) over time. This is a source of uncertainty for any of theconclusions reached by comparing these data.

Analytical Method Differences

In the various reports, metals have been reported as dissolved metals, total metals, and totalrecoverable metals (the same as acid extractable metals ). This means that the numbers in eachreport describe slightly different things. Dissolved metals are found by filtering a sample andanalyzing only the liquid portion for the metals. Other methods use various means to test both theliquid and suspended matter in the samples for metals. Therefore, if a sample has metals in both theliquid portion of the sample and the suspended matter in the sample, the maximum value of metalsreported in the sample will be a different number depending on which analytical method was used.

Quality Assurance/Quality Control (QA/QC)

All data provided to ATSDR was reviewed and incorporated in this document, regardless of the presence or absence of QA/QC information.

Detection Level Differences

The detection levels for the surface water and groundwater data are summarized on the following pages.

APPENDIX E: COMPARISON VALUES

ATSDR comparison values are media-specific concentrations considered to be "safe" under defaultconditions of exposure. They are used as screening values in the preliminary identification of"contaminants of concern" at a site. As ATSDR uses the phrase, a "contaminant of concern" ismerely a site-specific chemical substance that the health assessor has selected for further evaluationof potential health effects; the term does not imply any level of hazard. Generally, a chemical isselected as a contaminant of concern because its maximum concentration in air, water, or soil at thesite exceeds one of ATSDR's comparison values. This approach is conservative by design. If enoughdata were available, actual exposures could be estimated more accurately using the averageconcentration or a range of concentrations.

It cannot be emphasized strongly enough that comparison values are not thresholds of toxicity.Although concentrations at, or below, the relevant comparison value may reasonably be consideredsafe, it does not automatically follow that any environmental concentration that exceeds acomparison value would be expected to produce adverse health effects. In fact, the whole purposebehind highly conservative, health-based standards and guidelines is to enable health professionals torecognize and resolve potential public health problems before they become actual health hazards.The probability that adverse health outcomes will actually occur depends on site-specific conditionsand individual lifestyle and genetic factors that affect the route, magnitude, and duration of actualexposure, and not on environmental concentrations alone.

Listed below are the abbreviations for selected comparison values and units of measure used in thisdocument. Brief descriptions of the various comparison values that ATSDR uses to select chemicalsfor further evaluation follow this list.

Action Level (AL) is the concentration for lead defined in the Safe Drinking Water Act.

Environmental Media Evaluation Guides (EMEG) are concentrations that are calculated fromATSDR minimal risk levels by factoring in default body weights and ingestion rates.

EPA Soil Lead Guidance (EPA SLG) is the revised interim soil lead guidance for CERCLA andRCRA corrective action facilities; it is presented in OSWER Directive 9355.4-12, issued July 1994.

Maximum Contaminant Levels (MCLs) are legally enforceable drinking water standardspromulgated by the EPA. These are contaminant concentrations in drinking water that EPA deemsprotective of public health, considering the availability and economics of water treatmenttechnology, over a lifetime (70 years), at an exposure rate of 2 liters of water per day for an adult.

proposed Maximum Contaminant Levels (pMCLs) are nonenforceable drinking water standardsproposed by the EPA, but not finalized in a regulation.

Risk-Based Concentrations (RBC) are derived by the Region III Office of the EnvironmentalProtection Agency. They represent levels of contaminants (noncarcinogens and carcinogens, whenapplicable) in air, water, soil, and fish that are considered safe, assuming default values for bodyweight, exposure duration, and ingestion and inhalation rates.

Reference Dose Media Evaluation Guide (RMEG) is the concentration of a contaminant in air,water, or soil that ATSDR derives from EPA's reference dose (RfD) for that contaminant byfactoring in default values for body weight and intake rate. Different RMEGs are calculated foradults and children; this report uses values calculated for a child.

secondary Maximum Contaminant Levels (sMCLs) are legally enforceable standards set byEPA for contaminants that are not directly associated with health problem, but cause unpleasantaesthetic qualities in drinking water.

United States Geological Survey (USGS) finished water quality in public water suppliesbenchmark, cited in: The Water Encyclopedia, 2nd ed., Lewis Publishers, 1990, Table 6-26, p. 446.

United States Geological Survey (USGSb) health-based concentration for persons on a sodium-limited diet.

World Health Organization (WHO) guideline for aesthetic quality is 200 mg/l for a substance.The 20 mg/l guideline for sodium is based on a level acceptable for people on a sodium-limitingdiet.

References

Health Assessment Guidance Manual. Agency for Toxic Substances and Disease Registry, Atlanta, GA, 1992.

Drinking Water and Health, Vol. 3, National Academy Press, Washington, D.C., 1980.

EPA Region III Risk-Based Concentration Table, January-June 1996. United States EnvironmentalProtection Agency, Region III, 841 Chestnut Street, Philadelphia, PA 19107. Available on EPA Region III's Internet website:

http://www.epa.gov/reg3hwmd/riskmenu.htm?=Risk+Guidance .

van der Leeden F., Troise F.L., and Todd, D.K. 1990. The Water Encyclopedia, 2nd ed., Lewis Publishers: Chelsea, MI.

APPENDIX F: ATSDR's RESPONSE TO COMMENTS

Comments received during the public comment period for the Fort Belknap Indian Reservation/Zortman Mining Incorporated site and ATSDR's response to those comments are listed below. The comments are italicized, with ATSDR's response directly below.

1. Talking about the Grinnell Agreement of 1896 in the Background section of the public healthassessment is only used to make the public feel "bad" for the tribes and "hate" the white manand industry. This portion sets a bad mood for the reader going into the document.

In public health assessments, ATSDR typically discusses the site's history and ownership in theBackground section of the document, if such information is available. Ownership of a site maychange several times over the course of years. ATSDR's intent in including information from theGrinnell Agreement was only to provide the reader with background information about the area andsite history.

2. The Historic section seems to be unrelated to public health issues and appears more of anattempt to question the appropriateness of federal government actions from one hundred yearsago. Because this historic account differs in detail from other versions of the area history,citable documentation should be clearly distinguished from personal opinions. For example, isyour reference that the tribes vehemently opposed the "sale of the mountains" documented fact,or rather, more recent hearsay? Should there be a discussion of the 1895 value of $360,000? Isit true that, on the same visit to Montana Territories that resulted in the sale of this relativelysmall portion of the Little Rockies formalized in the Grinnell Agreement, the same commissionersalso established Glacier National Park, and that both agreements were thought to be in thepublic interest?

As noted in the previous comment, ATSDR typically discusses available site history information inthe Background section of the public health assessment. When appropriate, ATSDR staff referencethe historic information provided to the Agency. Please refer to the historic section to note theinformation that has been referenced. The actual dates (i.e., 1895) are provided to put historicinformation in perspective and no further information is deemed necessary. The establishment ofGlacier National Park is not relevant to this public health assessment.

3. In the context of this discussion and to make this historical setting relate to current healthconcerns, it would seem appropriate to include a discussion of possible shortcomings of thereservation system that may directly relate to the statistically high occurrences of substanceabuse and other health problems as documented by the Indian Health Service. Does the highrate of unemployment (reported to be 85%) or other social problems on the Fort Belknap IndianReservation result in anxiety, which could result to chronic health problems? These issues seemto relate much more directly to public health concerns.

Discussions of the possible shortcomings of the reservation system are out of the scope of this publichealth assessment. ATSDR staff did account for issues that may relate to public health in othersections of the public health assessment. For example, on the bottom of page 23, ATSDR states that"excessive tiredness and fatigue can be caused by the chronic anxiety that may be associated, in thiscase, with fear of potential exposures to chemical contaminants, the possibility of mine closure andcontinuing layoffs, long working hours, and driving long distances."

4. Further groundwater studies are to be conducted; therefore, isn't your report somewhatpremature, as the groundwater studies have not been conducted?

As stated in the Preface to the document, "The ATSDR Public Health Assessment: A Note ofExplanation," ATSDR acknowledges that this document represents the Agency's best efforts, basedon currently available information, to provide the community with an evaluation of the site's healthimplications within a limited time frame. As new data become available (i.e., groundwater data),ATSDR will modify the conclusions and recommendations for this site, if appropriate.

5. Page 17, fourth paragraph: "The maximum concentrations from domestic well datacompared between 1990-1995 and 1978", your report stated the levels were slightly higher (10-35%). I believe 35% is significantly higher. Also, your report did not mention the increase inarsenic levels from 1978 data compared to 1990-1995 data (Table 3). If these levels are goingto continue to increase in the future, at what level are they going to reach? Groundwater movesvery slowly through the aquifers, are these "slightly high values" just the beginning of theincrease in values that could show up in the future?

As stated in the public health assessment, the increases for specific conductivity, TDS, and sulfate donot appear to be out of the ordinary in view of the fact that historically the concentrations have beenhigh. Therefore, ATSDR does not consider the levels to be "significantly" higher. ATSDR cannotpredict future levels of contamination; however, the public health assessment indicated that the othersubstances (including arsenic) in the domestic well samples appear to be isolated detections andrepresent no apparent trends or pattern of groundwater contamination.

6. The draft public health assessment contains many unconditional statements regarding healthrisks to the Tribes that are based on unreliable information or incomplete analysis.

ATSDR has previously responded to this comment. Please refer to page 24 for a response to thiscomment.

7. The data sets used for this public health assessment are flawed. Some of the data is 18 yearsold, and apparently none was collected for the purposes of a public health study. Approximatelytwo-thirds of the data sets resulted from one-time sampling events. A variety of different entitiescollected the data, and the samples were tested using a variety of analytical methods.

ATSDR has previously responded to this comment. Please refer to page 6 (Statement of Issuessection) and the information contained in Appendix C and Appendix D.

8. The public health assessment makes only vague reference to data quality and says nothingabout the effects of data quality on the report's validity.

ATSDR has previously responded to this comment. Please refer to page 6 (Statement of Issuessection) and the information contained in Appendix C and Appendix D.

9. Because the ATSDR prepared this public health assessment without generating its ownenvironmental quality data, under controlled conditions, the ATSDR was forced to drawconclusions, often crucial ones, from data of questionable quality.

As stated in the Preface to the document, "The ATSDR Public Health Assessment: A Note ofExplanation," ATSDR acknowledges that in preparing this document, ATSDR has collectedrelevant health data, environmental data, and community health concerns from the EnvironmentalProtection Agency (EPA), state and local health and environmental agencies, the community, andpotentially responsible parties, where appropriate. For this public health assessment, ATSDRobtained a majority of the data from the Bureau of Land Management and ZMI's EnvironmentalImpact Statement. ATSDR does not collect its own data solely for the purpose of public healthassessments. ATSDR has included statements in our report in reference to the quality of the data. Please refer to page 6 (Statement of Issues section) and the information contained in Appendix Cand Appendix D.

10. The report contains conclusions about health effects of nearby mining activity and discussestrends in the data with no mention of the level of confidence upon which its conclusions rest.

ATSDR has previously responded to this comment. Please refer to page 6 (Statement of Issuessection) and the information contained in Appendix C and Appendix D.

11. The final report must also treat water quality and community health as the complex issuesthey are. The lives of Fort Belknap residents are affected by a myriad of influences that act incombination over many years. The residents do not have the luxury of eliminating, piecemeal,these factors from their lives, and neither should the ATSDR analysis of these factors.

The ATSDR public health assessment is a report that addresses the likelihood that exposure tocontaminants at the maximum concentrations detected would result in adverse health effects. Toaccomplish this, ATSDR evaluates each chemical of concern accounting for various factors. Whilethe relative toxicity of a chemical is important, the response of the human body to a chemicalexposure is determined by several additional factors: the concentration (how much); the duration ofexposure (how long); and the route of exposure (breathing, eating, drinking, or skin contact). Lifestyle factors (i.e., occupation and personal habits) have a major impact on the likelihood,magnitude, and duration of exposure. Individual characteristics such as age, sex, nutritional status,overall health, and genetic constitution affect how a human body absorbs, distributes, metabolizes,and eliminates a contaminant. A unique combination of all these factors will determine theindividual's physiologic response to a chemical contaminant and any adverse health effects theindividual may suffer as a result of the chemical exposure. The ATSDR public health assessmentattempts to address all of these various factors; hence, ATSDR has not eliminated the myriad ofinfluences that affect Fort Belknap residents from our evaluation.

12. The report should indicate where further data sampling is called for. The ATSDR is awarethat a community health evaluation will be performed on the reservation as a supplementalenvironmental project. Explicit recommendations from ATSDR for new research could make thisupcoming project more efficient and provide more useful information to all parties.

As the commenter states, ATSDR is aware of the supplemental environmental project. In fact,ATSDR staff provided input into the original project design and focus. Currently, ATSDR has beeninformed that the supplemental environmental project is on hold because ZMI filed for bankruptcyon January 15, 1998 in Reno, Nevada. If the project is resumed, ATSDR agrees to provide furtherassistance as needed in this effort.

13. This study has been done more than once. The same conclusions keep coming back. It istime to stop the expensive studies and very publicly show and admit that there are no healthproblems from ZMI.

ATSDR's mission is to "prevent exposure and adverse human health effects and diminished qualityof life associated with exposure to hazardous substances from waste sites, unplanned releases, andother sources of pollution present in the environment." ATSDR was petitioned in September 1995,by the Fort Belknap Community Council, and is under mandate by Congress to respond to allpetition requests. If future requests to review and evaluate additional data are received, ATSDRwill respond accordingly by providing the petitioner with whatever public health activities aredeemed appropriate.

14. The reference to the "water violation settlement" in the conclusion section is factuallyincorrect. A correct reference would be: the Consent Decree resulting from the lawsuitsettlement.....

Please refer to the main text in the conclusion section for this change.

15. The fourth conclusion does not reflect the data and discussions presented in the body of thereport. There is a wealth of compelling evidence pointing to a conclusion that water in theprivate wells is exactly what would be expected, given the aquifer characteristics of the geologicunits in which these wells are completed. There does not appear to be any evidence whatsoever,of a mine affect on these wells. For example, on page 16 you have included an applicablecitation: Data collected in the southwest portion of the Fort Belknap Indian Reservation goingback to 1936 indicate these same elevations of these same parameters [iron, manganese, TDS,and sulfate] (Feltis 1983). More recent data to the present suggests that these same parametersremain naturally elevated when compared to other aquifers more suitable to drinking water. Considering that this health assessment was petitioned based, to a large degree, on allegationsof mining effects on reservation well water quality, it would seem appropriate that the conclusionreflect the data review. We propose the following revision: "Private wells on the reservationalso contain aesthetically unappealing levels of iron, manganese, sodium, sulfate, total dissolvedsolids, specific conductivity, and pH. On the basis of the data reviewed by ATSDR, the levels ofthese constituents appear to be the result of natural conditions."

As stated throughout the public health assessment main text and in the health consultationscontained in Appendix B, ATSDR concurs that the levels of constituents in groundwater appear tobe naturally occurring. However, as stated in conclusion four, "it is not possible to conclusivelydetermine whether these elevated levels are naturally occurring or related to contamination from themine." ATSDR indicated under the section "Legal Actions" in the Background section of thePublic health assessment that the settlement required a "Ground Water Study Plan, which willprovide the information needed to determine whether or not there are impacts from mine wastewateron the area groundwater."

16. Clearly, in reference to conclusion five, natural biologic contamination is, by far, the mostlikely health risk in consuming water from springs and seeps, as would be the case in mostmountainous areas. Unless otherwise documented, this risk should be better clarified.

ATSDR addresses biologic contamination on page 19 of the public health assessment. ATSDRstated that King Spring has been posted as a biologic hazard. Because the Agency focuses, for themost part, on "chemical contamination" and not "biologic contamination," our conclusions centeraround adverse health effects, if any, that could be associated with exposures to chemicalcontamination. As stated in conclusion five, the exposures to springs and seeps are expected to beinfrequent and would not result in adverse health effects in adults or children.

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